Guide to
Clinical Trial Applications
AUT-G0001-9
DATE 29 JUNE 2015
This guide does not purport to be an interpretation of law and/or regulations and is for guidance purposes only.
HPRA Guide to Clinical Trial Applications
CONTENTS
ABBREVIATIONS
3
1
SCOPE
4
2
INTRODUCTION
4
3
REQUIREMENT FOR AUTHORISATION BY THE HPRA
5
4
APPLICATIONS FOR CLINICAL TRIAL AUTHORISATION
5
5
AMENDMENTS AND URGENT SAFETY MEASURES
11
6
END OF TRIAL DECLARATIONS
14
7
NOTIFICATION OF ADVERSE REACTIONS/EVENTS
14
8
SUSPENSION OR REVOCATION OF A TRIAL
17
9
APPEALS
17
10
END OF TRIAL REPORT
18
11
ARCHIVING
18
12
GCP INSPECTIONS
19
13
MANUFACTURING AUTHORISATIONS
20
14
ENFORCEMENT
21
APPENDIX 1 FEES AND ADDRESSES FOR THE APPLICATION
22
APPENDIX 2 LINKS TO WEBSITES REFERENCED IN THIS GUIDELINE
24
APPENDIX 3 LIST OF DOCUMENTS FOR SUBMISSION
25
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ABBREVIATIONS
CHMP
Committee for Medicinal Products for Human Use
EDI
Electronic data interchange
EEA
European Economic Area (EU and Norway, Iceland and Liechtenstein)
EMA
European Medicines Agency
EPA
Environmental Protection Agency
EU
European Union
GCP
Good clinical practice
GMP
Good manufacturing practice
HMA
Heads of Medicines Agencies
ICH
International Conference on Harmonisation of Technical Requirements for
Registration of Pharmaceuticals for Human Use
HPRA
Health Products Regulatory Authority
IMPD
Investigational medicinal product dossier
ICSR
Individual case safety report
MPR
Medicinal product report
RSI
Reference safety information
SUSARs
Suspected unexpected serious adverse reactions
SI
Statutory Instrument
SmPC
Summary of product characteristics
VHP
Voluntary Harmonisation Procedure
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SCOPE
This guide covers applications for clinical trials as defined in the European Communities
(Clinical Trials on Medicinal Products for Human Use) Regulations, 2004, SI No 190 of 2004.
Clinical trials which are outside the scope of the Regulations and therefore of this guide
include:
- Non-interventional trials which are not subject to legislative control when they meet the
definition in Regulation 4 of the Regulations.
- Clinical trials involving only medical devices, food supplements, or other non-medicinal
therapies (such as surgical interventions). For medical devices, please see the guideline on
clinical investigations on the HPRA website.
1
INTRODUCTION
This document is intended to give guidance to applicants in making applications for clinical
trials on medicinal products for human use to the Health Products Regulatory Authority
(HPRA) as competent authority for these Regulations. Guidance on applications to ethics
committees is available on the website of the Department of Health. Information on clinical
trials using medicinal products containing genetically-modified organisms is available from
the Environmental Protection Agency (see ‘GMO Part B Deliberate Release’). (Note that all
websites referenced in this document are listed in Appendix 2).
Clinical trials in Ireland are governed by the European Communities (Clinical Trials on
Medicinal Products for Human Use) Regulations, 2004, SI No 190 of 2004 and amendments.
The Regulations transposed into Irish law the provision of Council Directive 2001/20/EC on
the approximation of the laws, regulations and administrative provisions of the Member
States relating to the implementation of good clinical practice in the conduct of clinical trials
on medicinal products for human use. The Control of Clinical Trials Acts 1987 – 1990 for
clinical trials using medicinal products are superseded by these Regulations.
The definition of a clinical trial in the Regulations covers studies on clinical, pharmacological,
pharmacodynamic or pharmacokinetic effects or studies to identify adverse reactions to
investigational medicinal products, i.e. Phase I to Phase IV studies. Further guidance on the
definition of a clinical trial is available in Eudralex, Volume 10, Guidance Documents Applying
to Clinical Trials, Questions and Answers’ available on the website of the European
Commission. In particular, the decision tree provided in answer to question 1.1 in the
guidance is useful.
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Investigational medicinal products include placebo products and both authorised and
unauthorised medicines with any type of active substance, including herbal and homeopathic
products. Authorised products may be used in accordance with the terms of the marketing
authorisation or used in a different way, e.g. at a higher dose, for a new indication or when
packaged in a different container.
For additional guidance on making an application for clinical trials and on adverse reaction
reporting, applicants should also consult the EU guidelines which are available from the
EudraCT website or the website of the European Commission.
Applicants should note that the assessment of a clinical trial application and the assessment
of any subsequent application for product authorisation for the same medicinal product are
two separate assessments. The approval of a clinical trial does not determine the
acceptability or otherwise of the marketing authorisation application.
2
REQUIREMENT FOR AUTHORISATION BY THE HPRA
According to Regulation 10 of the Regulations, a trial may only be started or conducted in
Ireland if:
- the ethics committee has issued a favourable opinion
- the HPRA has granted an authorisation
- the sponsor or legal representative of the sponsor is established within the European
Community
3
APPLICATIONS FOR CLINICAL TRIAL AUTHORISATION
Applications for clinical trial authorisation should be made by the trial sponsor or a legal
representative acting on behalf of the sponsor. Applications should comply with the European
Commission’s guideline, ‘Detailed guidance on the request to the competent authorities for
authorisation of a clinical trial on a medicinal product for human use, the notification of
substantial amendments and the declaration of the end of the trial (CT-1)’ in Chapter 1 of
Volume 10 of Eudralex.
3.1
The application
Before an application can be submitted to the HPRA, sponsors must obtain a EudraCT
number by logging onto the EudraCT website and following the instructions to obtain a
security code and to apply for the EudraCT number. This number, and the e-mail confirmation
of the number, must be included with the application. Applications that do not comply with
these requirements will not be validated.
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The sponsor should then use this unique EudraCT number to create a EudraCT application
form and should ensure that the data provided in the EudraCT application form and the XML
file are identical and consistent with the protocol.
The submission of the form for ‘Additional National Requirements for a Clinical Trial
Authorisation’ is no longer obligatory. In its place, the HPRA has developed a list of
documents for submission (see Appendix 3) which can be used to facilitate preparation of a
new clinical trial application.
The application and all documents must be in the English language.
Applications to the HPRA are made by the sponsor or if he is not established in the
Community (i.e. EEA countries), his legal representative who is established in the Community,
or an applicant authorised by the sponsor to make the application.
3.2
Sponsors and investigators
Sponsors
As defined in Regulation 4 the ‘sponsor’ is the person who takes responsibility for the
initiation, management and/or financing of a clinical trial. The sponsor does not need to be
located in an EU Member State but must have a legal representative in the EU. The
investigator and the sponsor may be the same person.
The sponsor may delegate any or all of his trial-related duties and functions to another
person/organisation. Any duties or functions that are delegated to a third party must be
documented and specified in writing in the application form, or subsequently by amendment,
if changes to proposed arrangements are introduced. The sponsor remains ultimately
responsible for ensuring that the conduct of the trial and the data generated complies with
relevant Council Directives including 2001/20/EC, 2005/28/EC, 2001/83/EC and the Irish
Regulations.
For non-commercial multi-centre clinical trials, it is possible to have a local sponsor in
addition to an international sponsor.
Investigators
The relevant ethics committee is responsible for determining the suitability of an investigator
and the quality of the facilities at the clinical trial site.
3.3
Investigational medicinal product dossier
Quality, non-clinical and clinical supporting data on the investigational medicinal product
(IMP) should be provided in the investigational medicinal product dossier (IMPD). For further
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information please refer to the EU ‘Guidance on Investigational Medicinal Products (IMPs) and
other medicinal products used in Clinical Trials’ in Chapter III of Volume 10 of Eudralex. Note
that IMPs include not only the test product but also comparators, blinded comparators,
blinded test products and placebos.
The investigator’s brochure shall be presented in a concise, simple, objective, balanced and
non-promotional form that permits an unbiased risk-benefit assessment of the
appropriateness of the proposed clinical trial. Where the IMP already has a marketing
authorisation, the summary of product characteristics (SmPC) may be used instead of the
investigator’s brochure (simplified dossier).
The IMPD must contain reference safety information (RSI), to be used for assessing the
‘expectedness’ of adverse reactions that occur during a clinical trial. The cover letter
submitted with the application should clearly indicate the location of the RSI in the dossier.
For authorised products, this is usually within the Summary of Product Characteristics (SmPC)
and for unauthorised products, within the investigator’s brochure.
If the reference safety information is within the SmPC, the list of expected adverse reactions is
contained in Section 4.8 ‘Undesirable Effects’. Please note that relevant safety information
may also be contained in other sections of the SmPC, however only Section 4.8 should be
used for the purposes of expectedness assessment. If the investigational medicinal product
has marketing authorisations in several Member States with different SmPCs, the sponsor
should justify its selection of the most appropriate SmPC for the RSI, with reference to subject
safety.
If the reference safety information is within the investigator’s brochure, it should be in a
clearly identified separate section. This section should include a list of expected adverse
reactions clearly arranged according to their nature, frequency and severity (e.g. in tabular
format). If different indications are being investigated for the investigational medicinal
product, separate tables of expected adverse reactions by indication may be appropriate to
avoid misinterpretation of information e.g. oncologic indications and immune-mediated
indications.
If an investigator’s brochure is used as the RSI for an authorised product, any differences
between the list of expected adverse reactions in the investigator’s brochure and the SmPC
should be highlighted and justified.
If any product used in the trial is a genetically-modified organism, a separate application for a
licence must be made to the Environmental Protection Agency. For further details, please
contact the agency. A copy of the licence from the agency should be provided with the
clinical trial application.
Medicinal products used in the context of a clinical trial and not falling within the definition of
an IMP are ‘non-investigational medicinal products’ (NIMPs). The borderline between IMPs
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and NIMPs and the requirements for NIMPs is described in the EU guideline mentioned
above in this section.
If any product used in the trial requires a medical device for its administration or utilisation
refer to Eudralex, Volume 10, Guidance Documents Applying to Clinical Trials, Questions and
Answers’.
Where a medicine and a medical device are both under investigation, the study is required to
comply with the clinical trials legislation for the IMP and the medical devices legislation for
the device. A single application to the HPRA can be made which should include the
documents referred to in Appendix 3 pertaining to the IMP and the documents required for
the clinical investigation of a medical device. The application process will follow the timelines
set out in clinical trials legislation and no clock-stops are permitted. A single approval
decision will be issued for the study.
3.4
Labelling of the investigational medicinal product
The labels of the immediate and outer container should comply with the requirements of
Annex 13 to the EU Guide to Good Manufacturing Practices on ‘Manufacture of
Investigational Medicinal Products’ in Chapter III of Volume 10 of Eudralex. Label text must be
in English. Other languages may be included, though as far as possible, the text for each
language should be placed together on the label, rather than placing all language versions of
each statement together.
In relation to any changes to the expiry date on the label, the HPRA requires that an
additional label be fixed to the outer carton, with the new expiry date, the same original batch
number and an explanatory statement highlighting the fact that the expiry date shown on the
over-label is a new, approved date, and that the earlier expiry date on the outer and
immediate packaging has been superseded. This over-label should not cover either the old
use-by date or the original batch number. Any extension to the shelf-life is subject to the
submission of an amendment, unless otherwise agreed at the time of the original clinical trial
application.
3.5
Subject information and the informed consent procedure
The subject information leaflet and informed consent form should not be submitted to the
HPRA for information. The relevant ethics committee is responsible for providing an opinion
on these documents.
3.6
Ethics committee opinion
In order for a clinical trial record to be released into the EU Clinical Trials Register, the
decision taken by the competent authority on completion of the initial assessment
(authorised/ refused / withdrawn), the opinion of the ethics committee (favourable/ notfavourable/withdrawn) and their respective dates must be logged on the EudraCT database
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by the HPRA. The applicant must provide details of the ethics committee opinion to the HPRA
as soon as it is available to ensure that all Irish records are released and published on the EU
Clinical Trials Register.
3.7
Procedures for processing of the application
The procedures for authorisation of clinical trials depend on the type of investigational
medicinal product in the study. There are two categories of trials:
- general medicinal products, biological and biotechnological products
- advanced therapy medicinal products (gene therapy, somatic cell therapy, tissue
engineered products as defined in Article 2 of Regulation (EC) No 1394/2007), or products
containing genetically modified organisms
General, biological and biotechnological medicinal products
On receipt, applications are validated in order to check that all the required documentation is
present. If documents are missing, the applicant is asked to supply them, and the application
is not progressed further until they are provided.
Once validated, the application is assessed and within 25 days of receipt of a valid application,
written notice is sent to the applicant setting out either acceptance of the request for
authorisation, with conditions if necessary, or grounds for non-acceptance of the request. If
grounds for non-acceptance are sent, the applicant must respond with an amended request
(i.e., a response to grounds for non-acceptance) within 14 days. Following assessment of the
response and within 60 days of the original request, written notice is sent to the applicant
setting out either acceptance of the request for authorisation, with conditions if necessary, or
grounds for non-acceptance of the request.
Applicants should note that the Regulations allow for only one cycle of correspondence on
any queries which arise from the assessment. If a response is not submitted or the response
is not acceptable, the application is treated as rejected (alternatively the sponsor may
withdraw the application before day 60). Applicants may contact the HPRA, if necessary, to
discuss their responses before submitting them, in order to clarify the changes which are
required.
Advanced therapy medicinal products and genetically modified organisms
For advanced therapy medicinal product clinical trials and trials using genetically modified
organisms, the HPRA strongly recommends that the applicant requests a pre-submission
meeting to discuss the potential clinical trial submission. The HPRA may consult with its
experts before issuing the written authorisation for these trials.
The timelines for this procedure are as given below.
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On receipt, applications are validated in order to check that all the required documentation is
present. If documents are missing, the applicant is asked to supply them, and the application
is not progressed further until they are provided.
Once validated, the application is assessed and within 30 days of receipt of a valid application,
written notice is sent to the applicant setting out either acceptance of the request for
authorisation, with conditions if necessary, or grounds for non-acceptance of the request. If
grounds for non-acceptance are sent, the applicant should respond with an amended request
(i.e., a response to grounds for non-acceptance) within 30 days (or longer if the HPRA agrees).
The response is assessed by the assessors and by the Clinical Trials Subcommittee. Within 90
days of the original request, written authorisation is sent to the applicant setting out either
acceptance of the request for authorisation, with conditions if necessary, or grounds for nonacceptance of the request. Note: This timeframe may be extended in certain instances by an
additional 90 days as per Article 16.2 of the Regulations. The applicant will be notified in
writing if the timeline is to be extended.
Applications involving products for xenogenic cell therapy are not subject to any timelines, as
provided for in Regulation 16(9) of the Regulations.
Authorisations with conditions
The legislation permits authorisation of a clinical trial with conditions. The conditions are
agreed with the sponsor in advance of Day 60/90 and are included in the Day 60/90 approval
letter. The approval date is the date of the Day 60/90 letter. When the sponsor has made a
submission which addresses the conditions outlined in the approval letter, the HPRA will
respond indicating that the conditions have been satisfied. When the condition requires the
approval of a substantial amendment to the trial, the HPRA will issue an approval for the
amendment, however, the date of approval of the clinical trial remains the date of the Day
60/90 letter.
All application types
The EudraCT database, accessible to all competent authorities of Member States, is updated
with the outcome of the process.
3.8
Voluntary Harmonisation Procedure for the assessment of multinational clinical
trial applications
The Voluntary Harmonisation Procedure (VHP) is a procedure which makes it possible to
obtain a coordinated assessment of an application for a clinical trial that is to take place in
several European countries. It consists of the submission of a common dossier to the VHP
Coordinator and a coordinated assessment performed by the national competent authorities
concerned. After the VHP, a national clinical trial application needs to be submitted by the
sponsor according to the national laws for the approval of clinical trials. In the case of a
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positive outcome from the VHP, the national approval procedure should not take longer than
10 days after the submission of a valid application.
For detailed information on the process and requirements please refer to the guidance
‘Guidance document for a Voluntary Harmonisation Procedure (VHP) for the assessment of
multinational Clinical Trial Applications’ on the HMA website.
3.9
Pharmacogenetic Research
Pharmacogenetic research investigates how genetic variation affects the clinical response to a
drug, with the assumption that such knowledge could enhance the efficacy while reducing
toxicity. Clinical trials where samples for pharmacogenetic research are to be collected must
comply with GCP. The subject information leaflet and informed consent form must be
submitted to the relevant ethics committee for opinion. Pharmacogenetic research must
comply with data protection requirements. Further information on pharmacogenetic research
is available on the EMA and ICH websites.
4
AMENDMENTS AND URGENT SAFETY MEASURES
4.1
Amendments by the HPRA
The HPRA may require amendments to be made to the conduct of the trial to ensure
compliance with GCP or to ensure the safety or scientific validity of the trials. Where an
amendment is required, the HPRA will serve notice on the sponsor that a specified
amendment is required in 14 days, and will give the reason for the proposal.
The sponsor may make written representations to the HPRA within the 14 days, which will be
taken into account in the final decision. In order to consider the sponsor’s response, the
HPRA may delay the date on which the proposed amendment is to take effect.
4.2
Amendments by the sponsor
Substantial amendments
Amendments to a trial are regarded as ‘substantial’ where they are likely to have a significant
impact on the safety or physical or mental integrity of the clinical trial participants, or the
scientific value of the trial. It is up to the sponsor to assess whether an amendment is to be
regarded as substantial. Substantial amendments to the application or any accompanying
documentation must be notified to the HPRA using the EU ’Substantial Amendment
Notification Form.’ Further information on substantial amendments is provided in the EU
“Detailed guidance on the request to the competent authorities for authorisation of a clinical
trial on a medicinal product for human use, the notification of substantial amendments and
the declaration of the end of the trial, (CT-1).
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Any change to the RSI is considered a substantial amendment and should be justified with
supporting data. Amendments to the RSI should be clearly indicated using track change
formatting and mentioned in the cover letter. It is recommended that amendments to the RSI
are done in alignment with the development safety update report (DSUR). In this way the
DSUR can act in part as justification for the RSI changes, and the basis for expectedness can
remain consistent for the reporting period. If the RSI is updated prior to the end of the
reporting period of the DSUR, detailed justification with supporting data is required.
Non-substantial amendments
Non-substantial amendments do not have to be notified to the HPRA, however they must be
recorded and submitted with a subsequent substantial amendment notification. This is
particularly important for the clinical trial application form which should be updated in its
entirety on the occasion of a substantial amendment. The updated form (XML file) should be
submitted to the HPRA so that the EudraCT database can be updated. Non-substantial
amendments can be listed on the cover letter accompanying a substantial amendment. There
is no requirement to provide any documentation for the non-substantial changes.
Changes to the trial site or investigator
Substantial amendments relating to the clinical trial site or the investigator which are required
to be sent to the ethics committee should be notified to the HPRA following approval by the
ethics committee. A revised XML file with an updated list of approved trial sites/investigators
(Section G) should be submitted as part of the next substantial amendment application for
the trial.
Updates to the investigator’s brochure
In accordance with the legislation, the investigator’s brochure is required to be validated and
updated at least once a year. Revisions should be clearly indicated and justified. In particular,
any change in the 'expectedness' of an adverse drug reaction, including any increase in the
specificity or severity of a previously expected reaction should be addressed in the RSI. For
ongoing trials, if the RSI is not in a clearly identified separate section with the list of expected
adverse reactions clearly arranged according to their nature, frequency and severity (e.g. in
tabular format), this should be implemented at the next update.
Revisions to the investigator’s brochure can be substantial or non-substantial. The sponsor
should verify which revisions are substantial and submit these as substantial amendments.
If a decision cannot be made regarding the classification of an update as substantial or nonsubstantial, the sponsor is advised to submit the revised investigator’s brochure as a
substantial amendment to the HPRA. In addition, comment should be provided on the impact
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of any updates on the study and consequential substantial amendments to the protocol
and/or patient information leaflet should be submitted where necessary.
Documentation
Amendment applications consist of:
- Covering letter, including the EudraCT number, the CT number assigned by the HPRA, the
protocol number(s) affected by the amendment and the trial title
- EU ‘Substantial Amendment Notification Form’,
- Relevant extracts of the documents that are changed, highlighting current and proposed
wording, where applicable,
- New version of documents (including the clinical trial application form) if changes are
made
- Supporting data
A substantial amendment application may cover an amended document in more than one
clinical trial application which uses the same active substance, or it may cover a number of
amendments to different documents in the same clinical trial application. Where the
amendment relates to a number of clinical trial applications, the EudraCT numbers, CT
numbers, and protocol numbers must be clearly indicated in the cover letter.
Amendments to information that is assessed by both the HPRA and the ethics committee
should be submitted in parallel to both organisations.
Documentation on non-substantial and substantial amendments should be available on
request for inspection at the trial site and/or the sponsor’s premises, as appropriate.
Procedure for substantial amendments
Once validated, the application is assessed and, within 35 days of receipt of a valid
application, written notice is sent to the applicant setting out either acceptance of the request
for authorisation, with conditions if necessary, or grounds for non-acceptance of the request.
If grounds for non-acceptance are sent, the applicant must respond with an amended request
(i.e., a response to grounds for non-acceptance) not later than 30 days after receiving the
grounds for non-acceptance and at least 14 days before the amendment is due to be made.
Following assessment of the response and within 14 days of receipt of the response, written
notice is sent to the applicant setting out either acceptance of the request for authorisation,
with conditions if necessary, or grounds for non-acceptance of the request.
4.3
Urgent safety measures
If the sponsor and investigators consider that urgent safety measures need to be taken to
protect the health or safety of trial subjects, the sponsor should notify the HPRA in writing no
later than three days after the date the measures were taken. The notification should specify
the measures taken, the reasons for them and the plan for further action and should be sent
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to [email protected]. Urgent safety measures notified by telephone must be also be
notified in writing no later than three days after the date the measures were taken. An
amendment detailing the changes to the clinical trial documents should be submitted to the
HPRA as soon as possible after the implementation of urgent safety measures.
A temporary halt to a trial can be a substantial amendment or part of an urgent safety
measure. The restart of the trial should be treated as a substantial amendment with evidence
provided that it is safe to restart the trial.
5
END OF TRIAL DECLARATIONS
The end of a trial, whether it ends earlier than planned or according to the protocol, must be
notified to the HPRA using the EU Declaration of the End of Trial form. The form should be
submitted when the trial has ended in all countries in which the trial was taking place. If a trial
ends in Ireland before the trial has ended globally, it is recommended that the sponsor
notifies the HPRA in writing as justification for no longer submitting amendments or
Development Safety Update Reports (DSURs). This local end of trial date is also published in
the EU Clinical Trials Register.
The form should be received within 90 days of the end of the clinical trial or within 15 days if
it has ended earlier than planned.
6
NOTIFICATION OF ADVERSE REACTIONS/EVENTS
6.1
Reporting suspected unexpected serious adverse reactions
Suspected unexpected serious adverse reactions (SUSARs) occurring during clinical trials
undertaken in Ireland should be notified electronically and in parallel to both the HPRA and
the clinical trials module of the Eudravigilance database (EVCTM) by investigators or sponsor
pharmaceutical companies, in accordance with the ‘Detailed guidance on the collection,
verification and presentation of adverse reaction reports arising from clinical trials on
medicinal products for human use, CT-3’ and the requirements specified in the HPRA ‘Guide
to Electronic Submission of ICSRs and SUSARs Associated with the Use of Human Medicines’.
Paper reporting should be exceptional and in line with the ‘Note for Guidance on the
Electronic Data Interchange (EDI) of Individual Case Safety Reports (ICSRs) and Medicinal
Product Reports (MRPs) in Pharmacovigilance during the pre- and post-authorisation phase
in the European Economic Area.’
Whichever form/format is used, it is important that the basic information/data elements
described in Annex 3 of the above detailed guidance are included, when available, in any
expedited report.
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In exceptional cases, the HPRA will assist academic sponsors with electronic report
submission to EVCTM if necessary. In such cases, a request should be submitted to
[email protected] at the time of submission of the CT application, to facilitate timely
completion of arrangements
The timelines for expedited reporting are shown on the next page. The timelines start as soon
as the sponsor has first knowledge of the minimum criteria required for expedited reporting.
The timelines also re-start if/when additional case information becomes available.
Other safety issues requiring expedited reporting should be notified in accordance with the
criteria defined in the above detailed guidance document.
As a general rule treatment codes should be broken/unblinded by the sponsor before
reporting a SUSAR. However, in certain circumstances (e.g. trials in high morbidity or high
mortality conditions where efficacy endpoints could also meet the criteria for reporting as
SUSARs) and where it is considered that the integrity of the trial may be compromised if the
blind is systematically broken, sponsors should seek prior approval from the HPRA regarding
proposed arrangements for reporting of SUSARs. In such cases, an independent Drug Safety
Monitoring Board is recommended.
6.2
Monitoring and reporting of adverse events
The sponsor is required to keep detailed records of all adverse events relating to a clinical trial
which are reported to him or her by the investigators for that trial. The HPRA is entitled to
request these records.
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6.3
Line listings
Copies of line listings submitted to ethics committees, either quarterly or six-monthly, are not
routinely required by the HPRA. However it should be noted that copies of these line listings
may be requested and, as such, should be made available to the HPRA when required.
6.4
Development Safety Update Reports
In addition to the expedited reporting requirements of individual SUSARs, sponsors are
required to submit once a year or on request a safety report to the HPRA. Since September
2011, the Development Safety Update Report (DSUR) has replaced the EU Annual Safety
Update Report and differs from it in a number of ways. For example, there is a common birth
date, the Development International Birth Date (DIBD), the report includes information on the
marketing authorisation status worldwide, the cumulative exposure in clinical trials and
marketing experience (if applicable), and a summary of the important risks.
The main objective of a DSUR is to present a comprehensive, thoughtful annual review and
evaluation of pertinent safety information collected during the reporting period related to a
drug under investigation, whether or not it is marketed, by: (1) examining whether the
information obtained by the sponsor during the reporting period is in accord with previous
knowledge of the investigational drug’s safety; (2) describing new safety issues that could
have an impact on the protection of clinical trial subjects; (3) summarising the current
understanding and management of identified and potential risks; and (4) providing an update
on the status of the clinical investigation/development programme and study results.
A DSUR should be concise and provide information to assure regulators that sponsors are
adequately monitoring and evaluating the evolving safety profile of the investigational drug.
All safety issues discovered during the reporting period should be discussed in the text of the
DSUR; however, it should not be used to provide the initial notification of significant new
safety information or provide the means by which new safety issues are detected.
Guidance on the preparation on the report is provided in ICH Guideline E2F in Chapter II of
Volume 10 of Eudralex.
A DSUR should not be submitted as a substantial amendment; however the sponsor is
required to verify whether the data presented in the report require a change to the
documentation submitted with the request for authorisation of the clinical trial. If this
amendment is substantial, the rules for notification of substantial amendments apply to these
changes.
A DSUR is required to be submitted annually to the HPRA until after the last visit of the last
patient in Ireland or until the trial has ended in Ireland as defined in the protocol. A safety
evaluation, including data from the entire duration of the trial, should be included in the End
of Trial Report (see section 10).
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7
SUSPENSION OR REVOCATION OF A TRIAL
The HPRA may issue a notice to suspend or end the trial or to end it at one or more trial sites
if it considers that:
- the conditions of the approval or of application itself are not complied with, or
- there are doubts over the safety or scientific validity of the study, or
- there are doubts over the conduct of the trial at a particular site.
The notice will be sent to the sponsor, or the investigator at each site or particular sites as
appropriate. It will specify the actions to be taken, the duration of the actions and the
conditions which must be satisfied before the trial may recommence. The relevant ethics
committee, other Member States, the EMA and the European Commission will also be
informed.
The notice will be sent with immediate effect if the HPRA considers that there is an imminent
risk to the health or safety of trial subjects. Otherwise the sponsor or investigator will be
notified at least one week in advance and given the opportunity to make representations to
the HPRA. Any issued notice remains in force, even if appealed.
The suspension or revocation of a trial in another Member State may impact on the
authorisation of similar trials in Ireland.
The EudraCT database is updated following suspension, revocation or early termination,
temporary halt or re-start of a clinical trial.
8
APPEALS
A sponsor may appeal the decision of the HPRA to the HPRA’s Advisory Committee for
Human Medicine in the following cases where the HPRA has:
- authorised a trial with certain conditions
- issued grounds for not accepting a request for authorisation or for amendment of the
authorisation after the sponsor has amended the request
- amended a trial authorisation
- issued a notice for suspension or termination of a trial
An appeal must be sent within 28 days of the HPRA’s decision, unless further time is
requested and granted. The appeal will be considered by the committee, which will report its
findings to the Authority. The HPRA will notify the sponsor of the outcome of its
deliberations.
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9
END OF TRIAL REPORT
An end of trial report should be posted to the European clinical trials database (EudraCT),
managed by the European Medicines Agency (EMA) within 6, 12 or 24 months of completion
or cancellation of the trial. This applies if the trial is completed or terminated prematurely.
Guidance on the modalities and timing of posting of the report is available on the EudraCT
website.
Since 21 July 2014, it is mandatory for sponsors to post the end of trial report containing the
clinical trial results to EudraCT. This date corresponds to the finalisation of the programming
of the database as referred to in the European Commission guideline (2012/C 302/03), in the
application of the Clinical Trials Directive 2001/20/EC and in the Paediatric Regulation. Under
these frameworks, as sponsors start to comply with their legal obligation to provide end of
trial reports to EudraCT, summary results of clinical trials will become available via the publicly
accessible European Union Clinical Trials Register. The European Commission guideline on the
posting and publication of result-related information on clinical trials is available on the
website of the European Medicines Agency.
The format of the end of trial report should comply with the EU Note for Guidance on
Structure and Content of Clinical Study reports (CPMP/ICH/137/95), available on the website
of the European Medicines Agency.
When the trial is terminated prematurely, the end of clinical trial report should also provide
the following information:
- Justification of the premature ending of the trial
- Number of patients still receiving treatment at time of study termination,
- Proposed management of patients receiving treatment at time of study termination
- Consequences for the evaluation of results.
An end of trial report does not need to be submitted to the HPRA if it has been posted to
EudraCT.
10
ARCHIVING
The sponsor and the investigators are required to retain the essential documents relating to a
clinical trial for at least five years after its completion. The essential documents are defined as
those that individually and collectively permit evaluation of the conduct of the trial and the
quality of the data produced. These documents should be filed in an organised way that
facilitates management of the clinical trial, audit and inspection by competent authorities and
should be readily available on request.
The HPRA requires that if an end of trial report has not been submitted (see Section 10
above) then the essential documents should be retained indefinitely.
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Sponsors and investigators may be required by other applicable requirements to retain the
essential documents for more than five years. Further information is available in the EU
guideline on ‘Recommendation on the trial documentation and archiving.’
The requirements for marketing authorisation holders to arrange for the retention of retain
essential clinical trial documents by the owners of the data are outlined in Commission
Directive 2003/63/EC (in Volume 1 of Eudralex).
11
GCP INSPECTIONS
Good clinical practice (GCP) is a set of internationally recognised ethical and scientific quality
requirements that must be observed for designing, conducting, recording and reporting
clinical trials that involve the participation of human subjects. Compliance with GCP provides
assurance that the rights, safety and well being of trial subjects are protected, and that the
results of the clinical trials are accurate and credible. The Regulations require that all clinical
trials covered by the provisions of the Regulations, including bioavailability and
bioequivalence studies, are designed, conducted and reported in accordance with the
principles of GCP.
In addition to the principles of GCP, clinical trial sponsors should take into account other
applicable Community guidelines relating to the quality, safety and efficacy of medicinal
products for human use and updates as adopted by the CHMP, for example, the ‘Note for
Guidance on Good Clinical Practice (CPMP/ICH/135/95)’ and the ‘Detailed Guidance on the
Collection, Verification and Presentation of Adverse Reaction Reports arising from Clinical
Trials on Medicinal Products for Human Use, CT-3.’
Annex 13 to the ‘GMP Guide on Manufacture of Investigational Medicinal Products’ should be
complied with.
In accordance with Article 15(1) of Directive 2001/20/EC, any site involved in a clinical trial,
particularly the investigator sites, the manufacturing sites of the investigational medicinal
product, any laboratory used for clinical trial analyses and the sponsor’s premises may be
subject to inspection. Contract research organisations/contractors acting under arrangements
with a sponsor to perform some or all of the functions of the sponsor of a clinical trial may
also be subject to GCP inspection.
Inspections may be conducted on a routine basis, or may arise as a result of a specific trigger.
Inspections may be conducted on ongoing or completed studies and may be announced or
unannounced, however they are generally announced. In general, inspectees will be given
approximately one month’s notice of a forthcoming inspection.
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The following information may be requested from the inspectee prior to the inspection:
- Patient status per trial site (number randomised, drop-out rate, and number of serious
adverse reactions reported per site).
- Copies of company standard operating procedures e.g. (monitoring procedure, informed
consent procedure, serious adverse event reporting procedure, drug supply management
procedure).
- Trial-specific documents such as a copy of the current protocol and informed consent
form, source data verification guidelines, product handling instructions, laboratory manual,
randomisation code breaking procedure, monitoring plans and reports.
- Job descriptions and CVs of key site and sponsor personnel
- Any other documentation deemed necessary by the inspectors
An inspection plan, outlining the units to be inspected, the time and duration for each major
inspection activity and the schedule of meetings to be held with the investigator and/or
sponsor personnel, will be provided to the inspectee prior to the inspection.
In accordance with the legislation, the trial master file comprising the essential documents
which enable both the conduct of the trial and the quality of the data produced to be
evaluated must be available and shall provide the basis for the GCP inspection.
The conduct of a GCP inspection can vary depending on the scope and objectives of the
inspection. After an inspection, a report is issued to the inspectee. Responses to the report
should be provided within 30 working days of the date of issue. Once all findings and
observations of the inspection have been addressed satisfactorily, the inspectee will be
advised that the inspection is closed.
12
MANUFACTURING AUTHORISATIONS
Investigational medicinal products used in trials must be manufactured in accordance with
the requirements of the EU Guide to Good Manufacturing Practice. Each company responsible
for manufacture (including assembly or batch release) must have a manufacturing
authorisation which covers the investigational medicinal product. The authorisation is issued
by the competent authority in the Member State (including EEA countries) where the
company is situated and it must show that the manufacturer is authorised to manufacture or
assemble the relevant pharmaceutical form (e.g., solid dose forms, solutions for injection, etc).
Manufacturing authorisations for all manufacturing, assembly and batch release sites must be
provided as part of an application to conduct a trial.
Where a product is made outside the EU/EEA, the company which imports it into the EU/EEA
must hold a manufacturing authorisation for this ‘third-country’ importation. The qualified
person in the importing manufacturing company must satisfy him/herself of the GMP status
of the manufacturing site outside the EU/EEA. The HPRA also reserves the right to conduct
GMP inspections at such sites. With the exception of comparator products, it is not necessary
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for batches of investigational medicinal products to be re-tested on importation into the EU.
Where the importer does not have access to the original manufacturer of a comparator
product or, to the manufacturer's certification of the batch(es) concerned, each such batch of
comparator should be tested on importation. In all cases, each imported batch of an
investigational medicinal product must be released for use by the qualified person of the
manufacturer responsible for batch release.
The Regulations provide for an exemption from the need for a manufacturing authorisation
for certain manufacturing operations carried out in hospitals. No authorisation is needed for
labelling, packaging or re-packaging (including re-constitution) of a product by a doctor,
pharmacist or other person acting under the supervision of a pharmacist, when the product is
for use only in the hospital by a resident patient or an out-patient.
13
ENFORCEMENT
The HPRA is the responsible body for enforcement of the regulations and may prosecute for
any offences committed. The HPRA may also issue infringement notices where it has objective
grounds for considering that any person has contravened any provision of the regulations.
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APPENDIX 1 FEES AND ADDRESSES FOR THE APPLICATION
The HPRA strongly recommends electronic submission of clinical trial and related information
in line with the ‘Guide to Electronic Submissions - Human Medicines’.
Address for applications for clinical trial authorisation or amendment and development
safety update reports
[email protected]
or
HPRA Receipts and Validation section
Health Products Regulatory Authority
Kevin O’Malley House
Earlsfort Centre
Earlsfort Terrace
Dublin 2
Address for submission of urgent safety restrictions, end-of-trial declarations, reports,
and for responses to grounds for non-acceptance letters
[email protected]
or
Clinical Trials Unit
Health Products Regulatory Authority
Kevin O’Malley House
Earlsfort Centre
Earlsfort Terrace
Dublin 2
Address for reporting adverse reactions and SUSARs
[email protected]
or
Pharmacovigilance Section
Health Products Regulatory Authority
Kevin O’Malley House
Earlsfort Centre
Earlsfort Terrace
Dublin 2
or
Fax: +353 1 676 2517
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Address for manufacturing authorisation applications and amendments
[email protected]
or
Compliance Department
Health Products Regulatory Authority
Kevin O’Malley House
Earlsfort Centre
Earlsfort Terrace
Dublin 2
Fees for applications
The HPRA ‘Guide to Fees for Human Products’, the ‘Fee application form for human products’
and details on payment are available from the ‘Publications and Forms’ section of
www.hpra.ie. Payment is to be made with the clinical trial application. Fees are payable to the
account of the Health Products Regulatory Authority.
Swift Code: AIBKIE2D
IBAN: IE 54 AIBK 931012 33712185
Allied Irish Bank
1-3 Baggot Street Lower
Dublin 2
Clinical trials applications as well as substantial amendments of former VHP trials can be
submitted to the VHP Coordinator: [email protected].
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APPENDIX 2 LINKS TO WEBSITES REFERENCED IN THIS GUIDELINE
Website of the European Commission, Eudralex Volume 10: Clinical Trials contains:
- Chapter 1 Application and Application Form
- Chapter II Monitoring and Pharmacovigilance
- Chapter III Quality of the Investigational Medicinal Product
- Chapter IV Inspections
- Chapter V Additional Information (includes Questions and Answers Document referenced
in section 2 of this guideline)
Other European legislation is available in Volume 1 of Eudralex.
Website of the European Medicines Agency contains scientific guidelines as referenced in this
guideline.
Please see the ‘Publications and Forms’ section of www.hpra.ie for the following information
on clinical trials:
- Clinical Trial Subcommittee meeting dates and submission cut-off dates, for each year
- ‘Terms of Reference and Rules of Procedure of the Clinical Trial Subcommittee’
- ‘Guide to Clinical Trial Applications’
- ‘Clinical Trial Protocol Template’ (annotated with guidance for investigator-led trials)
Please see the Medical Devices section of www.hpra.ie for information on clinical
investigations of medical devices.
Website of the Department of Health contains:
- European legislation
- National legislation
- Guidance for ethics committees
Website of the HMA contains:
- Information on the Clinical Trials Facilitation Group
- Documents produced by the group, including the guidance document for the voluntary
harmonisation procedure referred to in section 4.8 of this guideline)
EudraCT is a database of all clinical trials commencing in the Community from 1 May 2004.
Website of the ICH contains:
- Quality, safety and efficacy and multidisciplinary guidelines and definitions
- The Guideline for Good Clinical Practice (E6(R1))
Website of the EU Clinical Trials Register contains publicly available information on
interventional clinical trials on medicines.
Website of the Environmental Protection Agency.
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APPENDIX 3 LIST OF DOCUMENTS FOR SUBMISSION
Please see below the list of documents for submission of a new clinical trial application.
1 Receipt of confirmation of EudraCT number
2 Cover letter, ‘in accordance with CT-1. The letter should indicate the specific features of
the trial population such as trial participants not able to give informed consent or minors
and whether the trial involves the first administration of a new active substance to
humans’
3 Valid EudraCT XML file
4 EudraCT application form (signed copy)
5 If the applicant is not the sponsor, a letter of authorisation enabling the applicant to act
on behalf of the sponsor
6 Protocol (with all current amendments), including summary
7 Investigator’s Brochure
8 Investigational Medicinal Product Dossier (IMPD)/ Simplified IMPD (incl. Section 2.1
Pharmaceutical information, Section 2.2 Pre-Clinical information, Section 2.3 Clinical
Information)
a) Summary of Product Characteristics (SmPC) for products with marketing
authorisation in the Community
9 Non-investigational medicinal (NIMP) dossier (if required)
10 Copy of the ethics committee opinion
11 Summary of scientific advice from any Member State or the European Medicines Agency
(EMA) for this trial
12 Copy of the EMA decision on the Paediatric Investigational Plan (PIP), where relevant
13
a) Copy of manufacturing authorisation(s) if the IMP is manufactured and/or batch
released in the EU/EEA
b) Copy of authorisation to cover trials or products with special characteristics e.g.
GMOs, radiopharmaceuticals
c) Declaration of the QP that the manufacturing site operates in compliance with GMP at
least equivalent to EU GMP, if manufactured outside the EU/EEA
d) Declaration of GMP status of active biological substances
14 Examples of labelling
15 HPRA fee form and proof of payment
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